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Get the structure right before it costs you.

Your entity, trust and ownership structure decides three things: how much tax you pay, how well your personal assets are protected, and how wealth passes to the next generation. Getting it wrong is expensive to undo.

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Aaron on business structuring.

The work

More than picking an entity.

Tax structuring is the design of the legal and ownership architecture your business, your assets and your family sit inside. It comes down to three things: how much tax you pay, how well your personal assets are protected, and how wealth passes to the next generation. Every entity choice, every trust deed, every shareholding decision has a consequence in all three, usually all at once.

Most owners inherit their structure from whoever set them up on day one, usually a Pty Ltd because it was quick and cheap, sometimes a family trust bolted on later when someone mentioned income splitting. That structure fitted the business you had then. The business you have now is bigger, more valuable, and carries risks the original design never contemplated. Structuring work is the deliberate redesign, done properly, with the tax-rollover reliefs the ATO actually gives you, so the change itself is not a taxable event.

A well-designed structure works like a firewall. Limited liability sits between the business and the family's personal assets. Separate entities sit between the active trading business and the passive investments (the property, the intellectual property, the retained cash), so a claim on one doesn't reach the others. It also gives access to the corporate tax rate: 25% or 30% for companies against 47% at the top personal rate, roughly 17 to 22 cents on every retained dollar. And it carries the business, and the wealth it builds, into the next generation: a family trust with the right appointor and beneficiary set-up can pass control and income to children and grandchildren without triggering CGT or estate contests. Done well, the structure sits underneath the business and quietly does its job for 20 years.

How it works

From current state to redesigned group in six steps.

STEP 01

Map what you have

We draw your current structure end to end: every entity, every shareholder, every trust, every loan account, every asset. Half the value of the exercise is that most owners have never seen the full diagram on one page.

STEP 02

Diagnose the fit

Against three lenses: tax efficiency, asset protection, and sale/succession readiness. We flag what’s working, what’s exposing you, and what’s costing you tax you don’t need to pay.

STEP 03

Design the target structure

The structure the business should be sitting in given where it is now and where it’s going in the next 5–10 years. Not the textbook answer, the answer that fits your family, your industry, your risk profile and your exit plans.

STEP 04

Model the transition

The tax cost, stamp duty exposure, Division 7A implications and rollover-relief eligibility of getting from A to B. Some restructures are effectively free using Subdivision 328-G or 122-A rollovers. Some cost real tax. You see the number before you commit.

STEP 05

Implement

Entity setup, trust deeds, share transfers, restructure documentation, ASIC and ATO registrations, Division 7A loan agreements, the whole build. Coordinated with your lawyer where legal drafting is required.

STEP 06

Embed and maintain

Structure is not a one-off. Trust distributions each year, Division 7A minimum repayments, corporate secretarial, annual review of whether the structure still fits. This is where the structuring work becomes part of your annual compliance rhythm rather than a document that ages in a drawer.

Triggers

Six moments where structure matters most.

Starting a business

The choices you make in year one are the cheapest to make and the most expensive to reverse. Pty Ltd, sole trader, partnership, trust. The right answer depends on what the business becomes, not what it looks like today.

Hitting $500k+ of profit

Once profit exceeds what you need to live on, the structure that was fine for a small business starts costing real money. This is the point at which a bucket company, a discretionary trust or a re-designed group typically pays for itself many times over.

Adding a partner or investor

Bringing in a co-owner, a key employee on equity, or an external investor almost always requires a structure the original setup didn’t anticipate (a holding entity, a shareholder agreement, sometimes an ESOP-ready share class).

Buying property or a major asset

Property inside the trading entity is exposed to every risk the business runs. Property in the wrong entity triggers CGT and stamp duty when you eventually want to move it. Structure the ownership before you sign.

Preparing to sell

The 12–36 months before a sale is when structure pays or costs the most. The small-business CGT concessions, the sale-of-shares-vs-assets question, the pre-sale dividend and franking-credit position, all of it depends on the structure you’re sitting in when the buyer arrives.

Family and succession events

A new child, a marriage, a divorce, a death, an intergenerational transfer. Every one of these events tests whether the structure still fits. Most don’t, because they were built for a family that no longer exists in that shape.

What it costs

Scoped fixed-fee, quoted upfront.

Every structuring engagement is scoped and quoted upfront. No hourly billing, no surprises. A short review-and-recommendation engagement for a small group sits at one end. A full diagnose-design-and-implement for a mid-sized group with multiple entities and legal drafting sits at the other. We give you the number before you commit, not after the invoice.

For clients on a Virtual CFO or Tax Planning retainer, the structuring work is scoped separately as a project and quoted at the start. The ongoing maintenance (annual trust resolutions, Division 7A tracking, corporate secretarial) sits inside the annual compliance fee.

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The building blocks

The entities we design with.

Most Australian business structures are built from the same handful of components. The skill is not knowing what they are. It’s knowing which combination fits your specific business, family and stage.

Company owned by a family trust

The workhorse combination for most Australian businesses. A Pty Ltd operating company gives limited liability and the 25%–30% corporate tax rate. A discretionary family trust owns the shares, so if the business is ever sued, the shares aren't in a founder's personal name. Owned individually, the Pty Ltd solves tax but leaves the shares exposed. Owned by a trust, both the liability firewall and the asset-protection layer are in place.

Discretionary (family) trust

The most flexible structure in the Australian tax system. Distributes income to beneficiaries who need it, in the amounts that make sense that year. Trustee resolution required in writing by 30 June every year.

Unit trust

Fixed entitlements to income and capital in defined proportions. The right vehicle when you have multiple unrelated owners who each need their own share, and for property held jointly with other parties.

Bucket company

A company that sits under the family trust and receives distributions taxed at 25% or 30%, capping the family’s marginal tax rate on retained profits. Then loans money back into the group under Division 7A rules. One of the highest-value structures we build.

SMSF

Self-managed super fund. The right home for genuinely long-term retirement wealth. For commercial property, an SMSF with a limited-recourse borrowing arrangement lets the fund buy the premises and rent them back to the trading business. Rent taxed at 15% in accumulation, 0% in pension phase, and the property is walled off from trading risk. Complex to run properly; expensive to run badly.

Partnership

Simple, transparent, useful for professional service firms with equity partners and for property held between two individuals. Not right for most trading businesses because it offers no liability protection.

Holding company

A parent Pty Ltd that owns the operating subsidiary, sometimes multiple operating subsidiaries. The right structure for businesses with multiple business units, for ESOP-ready groups, and for anything you want to be able to sell in pieces.

Asset protection / IP entity

A separate entity that holds the intellectual property, the brand, the goodwill or the equipment, and licences it to the trading company for a market-rate fee. Isolates the most valuable assets from operational risk, and creates a clean vehicle to sell or transfer the IP independently of the trading business.

A worked example

Transport group, owner-operator to $10m business.

Illustrative composite. Numbers are indicative of the kind of outcome this structure produces; not a specific client.

The before: Jack started as an owner-operator truck driver, sole trader, ABN in his own name, one truck. Business grew fast, profits taxed at his top marginal rate. He and his wife Diane owned their home jointly. If something went wrong at the business, the trucks, the goodwill and the family home were all exposed. Every dollar of retained profit sat in his personal balance sheet, taxed at 47%.

The work: Redesigned the group in three stages as the business scaled. Stage 1: moved trading into a discretionary family trust, asset protection restored, profits split between Jack and Diane. Stage 2: interposed a Pty Ltd operating company under the trust, 25%–30% corporate tax rate, limited-liability firewall between the business and the family. Stage 3: split out an asset company holding the trucks and equipment, and moved the commercial premises into a self-managed super fund with a limited-recourse borrowing arrangement, then rented it back to the trading business. Later added a holding company on top so two key operations managers could take equity through a single share class.

The result

  • Tax: ~$400k per year of retained profit taxed at the 25%–30% corporate rate inside the group rather than 47% at the personal margin. Commercial rent taxed at 15% inside the super fund; 0% once in pension phase.
  • Asset protection: Family home, investment property, retirement wealth and business IP all sit in separate entities from the trading risk. A trading claim can only reach the trading company, nothing else.
  • Sale readiness: Group is now sale-of-shares eligible. Small-business CGT concessions likely to reduce a future exit tax bill by seven figures on a $10m+ sale.
  • Employee equity: Two key managers now hold 10% of the group between them through the holding company. One share issue, one shareholders' agreement, no reissue across the underlying entities.

The trading business now runs behind a layered structure that quietly does its job. The next generation (Jack and Diane's kids) can inherit the family trust as it stands, without the business having to be sold to fund the estate.

What you get

From a structuring engagement.

Current-state structure diagram

Every entity, shareholder, trust and loan account in your group on a single page. Most owners haven’t seen this before we draw it.

Diagnostic report

Written assessment against tax efficiency, asset protection and sale/succession readiness. Specific flags, ranked by dollar impact.

Target structure design

The proposed end-state group with the reasoning behind every entity. Includes ownership percentages, appointed roles, and the sequence of steps to get there.

Transition cost model

The full tax, stamp duty and legal cost of restructuring, laid out step by step. Where rollover relief applies, we show the pre- and post-rollover tax positions.

Full implementation

Entity setup, trust deeds, share transfers, ATO and ASIC lodgements, Division 7A loan agreements, distribution minutes template. You end the engagement with a working structure, not a folder of recommendations.

Post-implementation forecast

A three-year forward model showing projected tax outcomes, cashflow to owners, and Division 7A minimum-repayment obligations under the new structure. The number you’d budget against and the KPIs to review every June.

Ready when you are

Let’s look at your structure.

Bring your current entity diagram (or we’ll sketch it on the call). 25 minutes. We’ll tell you whether the structure you’re in still fits, where it’s exposing you, and what a redesign would look like on the numbers. If nothing needs to change, we’ll say so.

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